Aviation safety expert John Goglia takes the FAA to task for its, um, creative approach to enforcing non-existent laws and regulations. Discussing the many questionable cease and desist letters that have been issued to operators around the country, he notes:
The impact on many operators–especially those holding airmen certificates–has been to cause them to cease operations and lose whatever business they may have been engaged in. The problem is those FAA letters weren’t issued legally and were, in fact, issued contrary to the federal aviation regulations, which authorize only FAA attorneys to issue orders and require any such orders to state specifically how the order can be appealed….
This issue is not going to just go away. The FAA needs to be repeatedly challenged in court, wherever possible.